Justia Utah Supreme Court Opinion Summaries

A jury convicted Petitioner of aggravated sexual abuse of a child, sodomy on a child, and attempted rape of a child. The court of appeals affirmed. On certiorari, Petitioner argued that the court of appeals erred in affirming the trial court's ruling that the state was not required to make a separate showing of good cause to admit the alleged victim's recorded statements under Utah R. Crim. P. 15.5. The Supreme Court affirmed the court of appeals, holding (1) a separate showing of good cause to admit a recorded statement is not required under rule 15.5; and (2) rather, good cause is established when the trial court considers all the factors in the rule and determines that the recorded statement is accurate, reliable, and trustworthy, and that admission of the recorded statement is in the interest of justice. View "State v. Nguyen" on Justia Law

Appellant, the biological father of Baby Girl T., challenged the district court's determination of his rights as a birth father and its grant of a motion in limine preventing his presentation of evidence. The court concluded that Appellant did not comply with the provisions of the Utah Adoption Act and therefore waived the right to notice of any judicial proceeding in connection with the adoption of Baby Girl T., as well as the right to refuse to consent to her adoption. It also barred Appellant from presenting evidence that the reason he failed to comply with requirements of the Act was because state employees negligently failed to register his notice of paternity proceedings prior to the birth mother's execution of a consent to adoption. The Supreme Court reversed and remanded, holding that the Act was constitutionally defective as applied to Appellant and deprived him of a meaningful chance to preserve his opportunity to develop a relationship with his child. View "In re Baby Girl T" on Justia Law

This appeal resulted from an action in eminent domain in which the Utah Department of Transportation sought to condemn an access point easement on property owned by FPA West Point. FPA's codefendant and lessee, Kmart Corporation, also claimed an interest in the access. Because of the different interests claimed by FPA and Kmart, FPA filed a motion asking the court to order separate just compensation determinations. The district court granted the motion. The Supreme Court held (1) the district court was correct in determining that the values of respective interests in a parcel of condemned property must be individually assessed; (2) the value of respective interests may be individually assessed in either separate or consolidated proceedings; (3) accordingly, the district court has discretion to order separate proceedings in an action involving multiple interest holders in a condemned parcel of property; and (4) because it was unclear whether the district court intended that FPA's and Kmart's interests be assessed through separate or through consolidated proceedings, the case was remanded with instructions to determine whether to order separate or consolidated proceedings in this matter. View "Utah Dep't of Transp. v. FPA West Point, LLC" on Justia Law

Defendant was charged with two counts of assault. He appeared for a jury trial and was subsequently convicted of a misdemeanor assault. Defendant appealed, claiming that his jury was assembled in a manner inconsistent with the requirements of the Equal Protection Clause. The Supreme Court disagreed and affirmed, holding (1) Defendant failed to timely preserve his Batson challenge, (2) the trial court did not err when it did not make findings or rule on the Batson challenge, and (3) Defendant's ineffective assistance of counsel claim based on his counsel's failure to timely preserve his Batson challenge failed under Washington v. Strickland. View "State v. Harris" on Justia Law

This case arose out of collective bargaining negotiations between the Utah Transit Authority (UTA) and Local 382 of the Amalgamated Transit Union (Union). Those negotiations came to a standstill in 2009 when the parties entered into arbitration and litigation to resolve their disputes. The district court granted UTA's partial motion for summary judgment in the ensuing litigation, and the Union appealed. Before the matter could be addressed on appeal, however, the arbitrator entered a binding ruling largely in favor of the Union. With this ruling in hand, the parties once again entered into negotiations and successfully hammered out a new collective bargaining agreement. The Supreme Court dismissed the Union's appeal because the dispute had been resolved and the case was moot. View "Utah Transit Auth. v. Local 382 of Amalgamated Transit Union" on Justia Law

Defendant entered into a plea agreement in 2005 in which the State promised to not oppose a motion to reduce his convictions. Defendant later filed a motion to reduce his convictions after successfully completing his probation, as required by statute. During his probation, however, the statute governing reduction of convictions was amended to bar reduction for crimes like Defendant's that triggered the sex offender registration requirement. The district court applied the amended statute retroactively to deny Defendant's motion. The Supreme Court reversed and remanded for reconsideration of Defendant's motion under the version of the statute in effect when he was initially sentenced, holding that the district court erred in applying the amended statute to Defendant's motion to reduce his convictions. View "State v. Johnson" on Justia Law

In 1985, Appellant was convicted of first degree murder and sentenced to death. In 2006, Appellant filed a successive postconviction petition for relief. In 2009, the district court dismissed Appellant's petition, holding (1) all claims were procedurally barred except the claim of ineffective assistance of postconviction counsel in the first Post Conviction Relief Act (PCRA) proceedings; and (2) Appellant's ineffective assistance of counsel claim was not timely brought. The Supreme Court affirmed the dismissal, holding (1) the district court did not abuse its discretion in denying Appellant's request for a six-month stay of proceedings; (2) the district court was correct in determining that all of Appellant's claims were procedurally barred except the claim of ineffective assistance of postconviction counsel; and (3) because Appellant did not make a showing of ineffective assistance, the Court did not need to consider whether the claim was time barred or whether Appellant had either a statutory or constitutional right to effective assistance of postconviction counsel. View "Carter v. State" on Justia Law

Appellant brought suit against his former employer, EnvironMax, and its directors to recover the value of shares he received to offset wages owed to him by the company - shares he claimed were diluted by corporate misdeeds. The district court dismissed Appellant's suit on summary judgment, concluding that the claim was derivative in nature and that Appellant lacked standing to assert it directly. In so ruling, the court concluded that EnvironMax was not a closely held corporation subject to an exception to the general rule requiring shareholder suits to be filed derivatively and that Appellant's direct claims were otherwise foreclosed by his failure to utilize the Utah dissenters' rights statute. The Supreme Court reversed, holding (1) because Appellant's alleged injury was an individual and not a collective one in common with all shareholders, Appellant was entitled to sue individually and not required to pursue his claim derivatively; and (2) the dissenters' rights statute does not preempt direct actions rooted in breach of fiduciary duty, such as the one brought by Appellant. View "Torian v. Craig" on Justia Law

Defendant was convicted of aggravated sexual abuse of a child, a first-degree felony, and dealing in material harmful to a minor, a second-degree felony. Defendant appealed his convictions to the court of appeals, asserting he should be granted a new trial because his trial counsel was ineffective. Specifically, Defendant contended that trial counsel did not properly investigate or exploit discrepancies in the victim's statements about whether the abuse occurred in 2002 or 2003. The court of appeals agreed and granted a new trial on both charges. The State conceded that Defendant's counsel acted ineffectively in defending the sexual abuse conviction, but petitioned for writ of certiorari on the harmful materials conviction. The Supreme Court affirmed the court of appeals' conclusion that Defendant was entitled to a new trial on the harmful materials conviction, holding that trial counsel's failure to press the time discrepancy was prejudicial. Remanded. View "State v. Moore" on Justia Law

The State filed a petition that charge D.B. as a principal with theft and criminal trespass for entering a construction site and removing a pair of bolt cutters. The juvenile court adjudicated D.B. a delinquent as an accomplice on both counts. The court of appeals affirmed. D.B. filed a petition for writ of certiorari, claiming that he did not receive adequate Sixth Amendment notice that he may be adjudicated delinquent as an accomplice for the charges. The Supreme Court reversed the delinquency adjudication on the criminal trespass charge but affirmed it on the theft charge, holding (1) D.B. received constitutionally adequate notice through trial testimony that he faced accomplice liability for theft; but (2) the juvenile court adjudicated D.B. delinquent as an accomplice for criminal trespass without notice. Remanded. View "D.B. v. State" on Justia Law